Firemen's Ins. Co. v. Commissioner
United States Board of Tax Appeals
1. Where in prior years a taxpayer deducted and was allowed as an operating expense the entire amount of expenditures made for additions and renewals of furniture and fixtures and the period of limitations has run against the adjustment of the returns for such years, no deduction may be allowed during the taxable year or years on account of depreciation of such property. 2. An amount paid by a corporation to a firm of accountants for services in connection with the…
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1. Where in prior years a taxpayer deducted and was allowed as an operating expense the entire amount of expenditures made for additions and renewals of furniture and fixtures and the period of limitations has run against the adjustment of the returns for such years, no deduction may be allowed during the taxable year or years on account of depreciation of such property. 2. An amount paid by a corporation to a firm of accountants for services in connection with the authorization and issuance of an increase in capital stock is not deductible as an ordinary and necessary expense of carrying on…
1Opinion of the Court
OPINION.
Trammell :
These proceedings, which were consolidated for hearing, are for the redetermination of deficiencies in income tax as follows:
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The only matters presented for determination are the correctness of the respondent’s action (1) in refusing, in each of the cases and in each of the years, to allow deductions for depreciation on furniture and fixtures which were acquired prior to the taxable years in controversy, the cost of such items having been charged to expense on the books of the taxpayers in the years in which paid, deductions therefor having been taken in the…
2Cases cited17 opinions
- United States v. LudeySupreme Court of the United States · 1927
- Holeproof Hosiery Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Emerson Electric Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- Giffin v. CommissionerUnited States Board of Tax Appeals · 1930
- Borg & Beck Co. v. CommissionerUnited States Board of Tax Appeals · 1931
12 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- General Bancshares Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
- Dunlap v. CommissionerUnited States Tax Court · 1980
- General Bancshares Corp. v. CommissionerUnited States Tax Court · 1962
- Herman v. CommissionerUnited States Tax Court · 1985
- Picker v. United StatesUnited States Court of Claims · 1967
14 more not listed; retrieve them via the Exa API.